How Coronavirus (COVID-19) affects UK private pilots

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During the current crisis, there has been a stream of notices, advice and guidance from the CAA, EASA and pilot organisations. It can be difficult to filter out the specific issues that affect private pilots, i.e. those with PPL, LAPL etc. and also spot what’s missing. It’s very easy to mix these up with derogations for commercial pilots. The CAA provided some exemption guidance in a simpler and easier to digest summary format in CAP 1946.

The length of the lockdown and other restrictions has led to many pilots having flown less and becoming much less current. The CAA issued some fairly generous exemptions and extensions during the first lockdown in 2020 but these have become more strict or not been renewed. Many pilots can expect (and would seek) some de-rusting or even a proficiency check once flying activities resume.

I’ve tried to simplify and clarify the key points below. This is a fairly fast changing situation, so while I have done my best you should beware that the statements below may already be incorrect or out of date.

Where can you fly?

During lockdown, current government guidance discourages private flights. Travel to/from an airport is illegal without a reasonable excuse, although these might include ferrying your aircraft to/from maintenance base or taking a short engine health flight.

The current GA guidance in relation to Covid restrictions permits GA flying for the purposes of work, and the CAA has confirmed with the DfT that this includes any activity that is “reasonably necessary” for an individual’s work, where there are no alternative options available. This would include pilots who need to keep up with required training or currency flights for their work; for example, a professional pilot or any pilot in possession of a current instructional qualification. Therefore, instructors are permitted to fly to maintain required training or currency. Instructors are not permitted to fly with students, with the exception of professional training as detailed above.

Foreign travel for leisure purposes is banned, although crew flying abroad in the course of their work are exempt.

SEP revalidation requires fewer flying hours

Schemes introduced in 2020 allowed pilots to extend their ratings by a few months with just a ground briefing. LAPL holders had their running expiry window extended from 24 to 32 months.

Both of these exemptions no longer apply.

A separate initiative was introduced during the winter of 2020 with the intention of making it cheaper, albeit more complex, where the UK CAA will allow those with 8 or more hours flown in the previous year to revalidate if they’ve had 1.5 hours instruction with an FI/CRI and/or recorded more take-offs and landings. The full details are found in ORS4 1416 and ORS4 1417. This scheme is temporary and runs until 30 April 2021.

For those who return to flying with an expired rating, then a short flight with an examiner will be required. This is a proficiency check rather than a skill test and can/should include some element of instruction. Although many pilots prefer to avoid anything considered a test, perhaps combining this with a general de-rusting/club check may be no bad thing. After all, the proficiency check is permitted to include some element of instruction.

Medical Certificate expiry dates no longer extended

During 2020, some extensions were granted for Medical Certificates. These have now time expired and won’t be replaced. Most AME’s are now operating again with extra safety measures, although giving priority to commercial pilots. I renewed mine in November 2020 any difficulty.

Fly VFR within the UK on a LAPL Medical or Personal Medical Declaration

The CAA is encouraging leisure pilots who don’t require a Class 2 to make use of either the longer duration of LAPL medical proficiency or a Personal Medical Declaration. For those who are not flying abroad (including the Channel Islands), instructing or flying IFR, either of these enable any PPL to fly with LAPL privileges – effectively any VFR flight in aircraft up to 2 tonnes within the UK. Your SEP rating must remain valid.

The PMD was introduced in 2016 and allowed PPL and LAPL holders to avoid the need to visit an AME. Provided they are healthy enough to drive a commercial truck and don’t suffer from one of a specific range of ailments, then can self-declare themselves as such. A one-off declaration is valid until aged 70, thereafter every three years. There is no cost to make a declaration, it just takes a few minutes on the CAA website. You must print out and carry the resulting declaration document with you alongside your pilot licence.

These cannot be used for flights outside the UK or for instructors/solo training or for IFR.

The PMD is valid for both EASA and non-EASA aircraft. This privilege will remain valid for non-EASA aircraft permanently. It was recently extended to cover EASA aircraft up to November 2019, but only if the declaration was made on or before 8 April 2020. [ORS4 1370]

PPL or LAPL - The Private Pilot's Licence Options in the UK

UK PPL and NPPL not valid for Part 21 aircraft

Having left EASA, the term for most certified aircraft has changed from EASA Aircraft to Part 21 Aircraft. Examples include the popular Cessna 172, Piper PA28, Diamond DA40 and Cirrus.

In the days before pan-European regulations and licences from JAR and EASA, the UK simply issued its own ICAO compliant licences. These older UK PPLs remain valid even today, although most pilots would have converted.

The UK chose to issue their own national UK PPL licence when EASA licences were introduced, arguing that these were required to hold any non-EASA ratings. It has caused a lot of confusion, duplication and excessive bureaucracy. I can’t say I’m aware of any UK specific ratings that need this anymore, and with hindsight perhaps it has been a complexity that perhaps could have been avoided.

We also have the inconveniently named NPPL (National PPL Licence), which was a forerunner of the European LAPL. These can host a microlight rating (which is what most micropilots would have) and/or an SSEA rating (which allows the holder to fly a larger fixed wing aircraft).

As of 7 April 2020, none of the above three types of licence (either type of national PPL or NPPL) can be used to fly a Part-21 aircraft. An earlier derogation that was given to enable that was not renewed. These licences remain valid for non-Part 21 aircraft (i.e. Permit Aircraft) and there are move afoot to restore the right to fly Part 21 using them again.

Aircraft Maintenance Regulations

There have been no alleviations or extensions for maintenance timescales. Aircraft Annuals, ARCs, 50 hour services (which also have a six month timeframe) all continue to apply. Your aircraft may not be legal to fly even if it has few hours since last service.

A significant change came into effect for light aircraft during March 2020, with the introduction of Part ML. For those flying private operations in aircraft less than 1200kg only (i.e. not flight training or commercial operations), this has less impact.

However, all flight schools and those owners of aircraft 1200kg or more will need to develop their own AMP (Annual Maintenance Program) and have this approved by their CAMO or CAO. An ARC (Annual Review Certificate) may not be able to be issued without one.

Many CAMOs may choose to downgrade to CAOs, which have fewer requirements but retain the most useful privileges required for general light aviation aircraft including ability to approve an AMP.

This is quite a complex change but has been poorly communicated to engineers and owners, so do read up on it and study the implications during the transition.

For those with Permit Aircraft, the LAA issued a statement about Permit Renewal which continues to operate by post as before. Permit Test Flights would of course be another matter entirely.

Private Pilots Licence — Cranfield Flying School

Students

PPL and LAPL students will have found that e-Exams were introduced on 5 October 2020. You should, if you haven’t already, apply for a login ID on the UK CAA Portal so that you can register for e-Exams in future. It typically takes about five days to process a new registration.

The maximum period of 18 months to pass all your PPL/ATPL theory exams remains – an earlier extension was not renewed.

Last Updated 10 Feb 2021

5 comments

  1. Hi David

    Great writeup here.

    I tried to decipher the CAA rules too on Personal Medical Declaration…however, can you just clarify I think the PMD does not apply for IR(R) or IR privileges.

    So I guess that means we PPL holders will not be able to exercise those rights until they hold a full medical again.

    1. For EASA aircraft, you do need at least a Class 2 medical to fly IFR, which can remain valid using the exemption above.
      A PMD is sufficient to fly IFR only in a non-EASA aircraft with IMC rating privileges (not full IR privileges), and only in UK airspace.
      See CAA PMD webpage

  2. Thanks David for the time spent trawling thru the often ambiguous text in CAA docs, as did John.
    It is appreciated and the latest extensions shows a glimmer of light to reduce complexity for and the demand placed on the regulators keeping all sorts of red-tape scenarios simple. Hope you and family all well, Allan

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